CHIME to HHS: Extend Certification Criteria to HIE Market

The government should explore ways to extend the concept of certification to the health information exchange marketplace to advance interoperability, the College of Healthcare Information Management Executives (CHIME) said in comments submitted to Health and Human Services (HHS) recently.

The Centers for Medicare & Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC) released a joint request for information (RFI) March 7, outlining several possible changes to policies and programs to advance interoperability and health information exchange. Some questions in the RFI seek feedback on the ability of payment system reforms, such as ACOs or bundled payments, to advance interoperability; other questions ask if changes to Conditions of Participation might be leveraged to encourage more exchange.

CHIME answered all the questions posed by CMS and ONC in their response, focusing on a need to address technical barriers related to exchange. “CHIME believes that the certification process, developed under the EHR Incentive Payments program, has had a major impact on the adoption and meaningful use of health information technology,” the organization said in a response to the RFI. “As a policy lever, the impact of certification criteria developed for Meaningful Use cannot be understated. Thus, CHIME recommends HHS extend the concept toward the health information exchange market, via standard interfaces, standard methods for isolating sensitive information, standard means to securely transport patient care information (i.e., Direct), standard ways to accurately identify patients and standard protocols for tracking consent.”

The organization of healthcare CIOs urged both ONC and CMS to continue a strategy that enables local flexibility, while leading stakeholders in the development of specific technical standards, services, and policies that solve core problems, reduce costs and complexity, and facilitates nationwide interoperability.

CHIME also supported the payment model changes underway at CMS and the CMS Innovation Center, also known as CMMI, as a way to enhance interoperability by creating a stronger business case for providers to exchange health information. “CHIME believes CMS should continue the evolution of payment policies towards pay-for-value and away from fee-for-service,” the letter said. But the letter also urged caution in applying blanket mandates to participate in exchange, saying, “While we believe any model of accountable care delivery cannot be successful without robust technology usage, CHIME believes that forcing miscellaneous exchange through requirements for participation, receipt of incentive payments, or avoidance of payment adjustments is a serious proposition—one that needs broad input from stakeholders.”

Another important area highlighted by CHIME in its response, includes the issue of positive patient identification and accurate patient data-matching. “As exchange increases from other treating providers outside of their primary practice or system, patient data-matching errors and mismatches will become exponentially more problematic and potentially dangerous. As stated in a survey of CHIME membership from May 2012, ‘Unintended injury or illness attributable to patient data-matching error is a considerable, and growing, problem in this era of health information exchange. And with a substantial portion of CIOs involved with HIEs that use differing approaches to data matching, we can expect the inconsistency and variability inherent to healthcare IT systems to persist—and become more endemic—without national leadership and consistent standards.’ While technologies, architectures and strategies exist to mitigate errors, CHIME encourages CMS and ONC to dedicate substantial resources to this foundational challenge.”